## State of California

Staff Report



# Analysis of the San Joaquin Valley

2008 PM2.5 Plan

Release Date: May 7, 2008 Scheduled for Consideration: May 22-23, 2008 California Environmental Protection Agency



# AIR RESOURCES BOARDThis document has been reviewed by the staf f of the California Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Air Res ources Board, nor does the mention of trade names or commercial products constitute endorsement or recommendation for use.

Electronic copies from this document are av ailable for download from the Air Resources

Board’s Internet site at: http://www.arb.ca.gov/plannin g/sip/sjvpm25/sjvpm25.htm

. In addition, written copies may be obtained from the Public Information Office, Air Resources Board, 1001 I Street, 1 st Floor, Visitors and Environmental Services Center, Sacramento, Californi a 95814, (916) 322-2990.

For individuals with sensory disabilities, this document is available in Braille, large print, audiocassette or computer di sk. Please contact ARB's Disability Coordinator at (916) 323-4916 by voice or through the Californi a Relay Services at 711, to place your request for disability services. If you are a person with limited English and would like to request interpreter services, please c ontact ARB's Bilingual Manager at (916) 323-7053.

For questions, contact:

Ms. Sylvia Zulawnick or Patricia Velasco, Ph.D. Manager, PM Analysis Sect ion Project Lead Phone: (916) 324-7163 Phone: (916) 323-7560

Email: szulawni@arb.ca.gov Email: pvelasco@arb.ca.gov

P.O. Box 2815 Sacramento, California 95812PRINCIPAL AUTHOR

Patricia Velasco, Ph.D., Project Lead

PROJECT MANAGERS

Sylvia Zulawnick, Manager, Part iculate Matter Analysis Section Karen Magliano, Chief, Air Quality Data Branch

CONTRIBUTORS

Air Quality and Transportation Planning Kurt Karperos, P.E., Chief, Air Qua lity and Transportation Planning Branch Ravi Ramalingam, P.E., Manager, Tr ansportation Strategies Section Jeff Lindberg, Planning Liaison to the San J oaquin Valley Air Pollution Control District Kyriacos Kyriacou, Ph.D., Air Resources Engineer

Air Quality Data Branch Katazyna Turkiewicz, Air Pollution Specialist Eugene Kim, Ph.D., Ai r Resources Engineer

Air Quality Modeling John DaMassa, Chief, Modelin g and Meteorology Branch Vernon Hughes, Manager, Atmospheric Modeling and Support Section Ajith Kaduwela, Ph.D., Manager, Regi onal Air Quality Modeling Section Kathleen Fahey, Ph.D., Air Pollution Specialist Cheryl Taylor, Air Resources Engineer

Emission Inventory Karen Buckley, Manager, Emission Inventory Systems Section Martin Johnson, P.E., Staf f Air Pollution SpecialistACKNOWLEDGMENT

ARB staff thanks the staff of the San Joaquin Valley Unified Air Pollution Control District for the high level of coordination betw een the agencies in the development of the technical elements of this plan.TABLE OF CONTENTS

EXECUTIVE SU MMARY ................................................................................................ 1

I. BACKGRO UND...................................................................................................... 1

A. Profile of the San Joaquin Valley ............................................................... 1

B. PM2.5 Health Effects and Fe deral Air Quality Standards ......................... 3
C. Air Quality .................................................................................................... 3

D. California Regional Particulate Ma tter Air Quality Study (CRPAQS) ...... 6

II. AIR QUALITY PLANNING ..................................................................................... 8

A. Air Quality Planning Background .............................................................. 8

B. Recent Air Quality Planning ....................................................................... 8
C. General Planning Requirements ................................................................ 9

III. PLAN EVAL UATION............................................................................................ 10

A. Overview of the San Jo aquin Valley PM2.5 Plan .................................... 10

B. Emission Inventory ................................................................................... 11

1. Estimating Emissions ............................................................................... 11

2. Summary of Baseline Emissions ............................................................. 12
C. Air Quality Modeling .................................................................................. 15

1. Grid-based Photochemical Modeling ....................................................... 15

2. Weight of Evidence .................................................................................... 16

3. Demonstrating Attainment ........................................................................ 17

4. Attainment Date ......................................................................................... 19

D. Control Strategy ........................................................................................ 20

1. New District Measures .............................................................................. 21

a. Rule Development Commitment .................................................................. 21

b. Incentive-based Strategies ........................................................................... 25

2. Adopted State Strategy ............................................................................. 26

E. Reasonable Further Progress .................................................................. 28

F. Contingency Measures ............................................................................. 28

G. Reasonably Available Control Measure Analysis ................................... 29

1. District RACM ............................................................................................ 29

2. Metropolitan Planning Organizations RACM .......................................... 29

H. Transportation Conformity Budgets ........................................................ 30

I. Environmental Impacts ............................................................................. 31

IV. STAFF RECO MMENDATION .............................................................................. 31

APPENDIX A - Regional Air Quality Modeling APPENDIX B - Weight of EvidenceES-1 EXECUTIVE SUMMARY

On April 30, 2008, the San Joaquin Valley Air Pollution Control Distr ict (District) adopted a PM2.5 Attainment Plan showing how the re gion will comply with the federal PM2.5 air quality standards set by the U. S. Environmental Protection Agency (U.S. EPA) in 1997. The staff of the Air Resources Board (A RB or Board) has reviewed the Plan and recommends that the Board appr ove it as a State Implement ation Plan (SIP) revision to
be submitted to U.S. EPA. The Plan shows that the region now m eets the daily (24-hour) standard, and demonstrates how the more challenging annual standard will be met by 2014. The Plan documents that emissions of PM2.5 particles, and the pollutants that form PM2.5, are decreasing each year. A mid-course review of plan implementation will be done in 2 011 as required by U.S. EPA

The Plan consists of adopted measures that provide increasing benefits each year, along with new emission reduction commitment s from both ARB and the District. The Valley’s particle pollution problem is well studied as a result of the $27 million invested in the California Regional Particulate Matter Study. This study provides the scientific foundation for the PM2.5 SIP by identifying the pollutants most important to formation of PM2.5 pollution. The results indicate that the key pollutants to reduce are NOx, SOx, and directly emitted PM2.5 particles. The Plan addresses these three pollutants consistent with U.S. EPA guidanc e. Emissions of VOC are also being reduced in the region as part of the ozone attainment stra tegy but are not required to be included in
this SIP.

Overall, between 2005 and 2014, NOx emissions will decrease by almost 300 tons per day (tpd), direct PM2.5 emissions by over 20 tpd, and SOx by almost 3 tpd. Two thirds
of the NOx and SOx re ductions and one half of the PM 2.5 reductions come from already adopted measures. A significant po rtion of the new commitments come from the ARB’s State Strategy t hat was adopted in September 2007. The State Strategy provides an additional 76 tons of NOx reductions and 5 tons of PM2.5 reductions in
2014. The District has accelerated several measures in its 2007 Ozone Plan that are also part of the PM2.5 attain ment strategy, and targeted a number of categories of

PM2.5 for additional emissi on reductions, including resi dential wood burning and commercial cooking. Past District effo rts to reduce impacts from residential wood burning have proven to be very effective, and continued reductions in this source category are expected to contribute si gnificantly to further progress.

As emissions have decreased each year, part s of the Valley are already meeting the annual standard. The air qualit y modeling indicates that attaining the annual standard in the southern Valley is the biggest challenge, but all areas are proj ected to attain the standard by 2014. The Plan will also bring t he region much closer to meeting a new federal PM2.5 standard that will apply to futu re SIP planning efforts. SIP planning for
the newer standard will occur after U.S. EPA designates nonattainment areas and develops implementation rules.ES-2 The Plan demonstrates the rate of emissi on reductions that will occur between now and the attainment year. As shown below 307 tons per day of reductions are needed

between 2005 and 2014. The Pl an outlines how these reduc tions will be achieved. While the majority of the reduc tions are NOx, it is important to recognize that the PM2.5 reductions are also essential because air qu ality modeling shows ea ch ton of direct PM2.5 is approximately nine times more effective t on per ton in the attainm ent year.

Staff’s review indicates that the Plan meets the requirements of the Clean Air Act (Act) and U.S. EPA’s PM2.5 implementation rule . The SJV 2008 PM2.5 Plan demonstrates attainment as expeditiously as practicable, no later than 2014, as required by the Act. The Plan also includes reasonable further pr ogress calculations, reasonably available control measures and technologies, cont ingency measures, emis sion inventories, transportation conformity budgets, and a co mmitment for a SI P update in 2011. Additional reductions from adopted ARB measures will provide NOx reductions for contingency purposes should the region not attain in 2014.

The PM2.5 Plan is the result of a two year effort to update the emission inventories for each mobile, stationary, and area source ca tegory, conduct air quality modeling and data analysis, and to develop new control st rategies. The 2011 SIP update will provide an important opportunity to assess air qua lity progress, update em ission inventories, and check on the progress in achieving emission reductions.

Recommendations: Staff recommends that the Board approve the District’s 2008

PM2.5 attainment Plan. Countdown to Attainment Levels

0 50 100 150 200 250 300 350

2005 2009 2012 2014Emission Reduction Needed (tpd)

NOx PM2.5 All SIP reductions

achieved1 I. BACKGROUND

A. Profile of the San Joaquin Valley

Covering nearly 25,000 square miles, the San Joaquin Valley is one of the dominant features in California’s landscape. One of the fastest growing regions in the State, the Valley is home to more t han 3.6 million people. The Va lley has four large cities, Stockton, Modesto, Fresno, and Bakersfiel d, each with a population greater than 200,000. Numerous smaller cities and town s in the Valley are separated by large expanses of agricultural lands. With urbani zation, agricultural lands continue to be converted to non-agricultural uses.

The San Joaquin Valley Air Basin is a lowl and area bordered by the Sierra Nevada Mountains to the east, the Pacific C oast range to the west, and the Tehachapi

Mountains to the south. The mountains ac t as air flow barriers, with the resulting stagnant conditions favoring the accumulation of emissions and pollutants. As a result, PM2.5 concentrations are higher in the sout hern and central portions of the Valley, where geography, emissions, and climate pose significant challenges to air quality

progress.

PM2.5 is a complex mi xture of many different specie s generated from a wide array of sources. PM2.5 can be either emitted directly into the air (primary particles) in forms such as soot, smoke, and the tiniest spe cs of dust, or it can be formed in the atmosphere (secondary particles or aerosol dr oplets) from the reactions of precursor gases, nitrogen oxides (NOx), sulfur oxides (SOx ), reactive organic gases (ROG), and
ammonia. NOx and ROG are al so precursors of ozone pol lution. Understanding the nature of the PM2.5 problem is key to designing an effective control strategy.

In the Valley, the levels and nature of PM2.5 concentrations typically differ by season (Figure 1). Higher PM2.5 concentrations occur during the winter, between late November and February during extended periods of stagnant weather with cold, damp, foggy conditions, which are conducive to t he formation of secondary ammonium nitrate particulates. At these times, PM2.5 is dominated by ammonium nitrate formed from NOx and ammonia emissions, and directly emi tted particles, such as wood smoke and

other combustion sources.2 Figure 1. Seasonal Variati on in PM2.5 Concentrations in the San Joaquin Valley.

The elevated winter PM2.5 concentrations dr ive the annual average PM2.5 levels. On an annual basis, PM2.5 in the Valley consists mostly of ammonium nitrate, organic carbon, and ammonium sulfate (F igure 2). Ammonium nitrat e is formed from chemical
reactions of NOx emitted fr om motor vehicles and stati onary combustion sources with ammonia. Burning activities, such as resi dential wood combustion, cooking, and direct tailpipe emissions from mobile sources are major sources of organic carbon.

Ammonium sulfate is also formed in the at mosphere from chemical reactions of SOx

emitted from combustion sources and ammonia. To a lesser extent, elemental carbon resulting from mobile and stationary combus tion sources, and geological material from roads and other dust producing activiti es also contribute to PM2.5.

Figure 2. PM2.5 Compositi on in the San Joaquin Valley Seasonal Variation in PM2.5

San Joaquin Valley (2006)

0 5 10 15 20 25 30 35 40

1 2 3 4 5 6 7 8 9 10 11 12

MonthConcentrations (ug/m3)

Fresno-1st Bakersfield-California

2004-2006 Average Composition

Bakersfield

Geological

6%

Ammonium

Sulfate

13% Organic

Carbon

35% Ammonium

Nitrate

39% Elemental

Carbon

5% Elements

2% 2004-2006 Average Composition

Fresno

Geological

4%

Organic

Carbon

41% Ammonium

Sulfate

11% Ammonium

Nitrate

37% Elemental

Carbon

5% Elements

2%3 B. PM2.5 Health Effects and Federal Air Quality Standards

Extensive research over the last two decades has investigat ed the effects that breathing PM2.5 has on people’s health. Research studies have consistently found a link between PM2.5 exposure and pr emature death in people with existing cardiac or respiratory disease. Studies of large populations have found that exposure to PM2.5 is

associated with increased hos pital admissions and emergency room visits due to frequent and severe asthma attacks, pneumoni a, and acute and chronic bronchitis, primarily in people with chronic heart or l ung diseases. Long-term exposure to PM2.5 has also been linked to an increase in lung canc er mortality risk. Those most at risk of experiencing adverse effects with PM2.5 exposure include infants, ch ildren, the elderly, and persons with pre-existing cardiopulmonary disease.

U.S. Environmental Protection Agency (U .S. EPA) adopted national ambient air quality standards (NAAQS) for PM2.5 in 1997, with a 24-hour PM2.5 standard of 65 micrograms per cubic meter (μg/m 3 ) and an annual standard of 15 μg/m 3 . State Implementation Plans (SIPs) for areas des ignated nonattainment for these standards are due to U.S. EPA in 2008. The San Joaq uin Valley is currently designated as
nonattainment for the 1997 PM2.5 standards and the 2008 SJV PM2.5 Plan addresses these standards. In 2006, U.S. EPA adopted a new 24-hour PM2.5 standard that will apply to future SIP planning efforts. SIP planning for the newer standard will occur after U.S. EPA designates nonattainment ar eas and develops implementation rules

C. Air Quality

While the San Joaquin Valley has one of the mo st severe PM2.5 problems in the nation, PM2.5 air quality has shown considerable improv ement. Initial efforts to monitor PM2.5 began in 1990. Annual average PM2.5 c oncentrations decreased between 20 to 30 percent during the period of 1990 through 2001. Due to the marked and complex variability in the Valley’s meteorological co nditions, some years are far more conducive

to PM2.5 formation and accumulation than other s. However, overall concentrations show a downward long-ter m trend (Figure 3).4 Figure 3. Long-term Trends in PM2.5 Con centrations in the San Joaquin Valley

Since 1999, when monitoring for compliance with the federal PM2.5 standards began, PM2.5 annual average concentrations have dr opped a further 19 to 29 percent. When the San Joaquin Valley was first designa ted nonattainment for the federal PM2.5 standards, the basin exceeded both the annual and the 24-hour PM2.5 standards. However, based on 2004-2006 da ta, the San Joaquin Valley no w meets the federal 24-hour PM2.5 standard of 65 ug/m 3. Thus, this SIP focuses on what more is needed

to attain the annual standard.

For planning purposes, U.S. EPA recommends using the average of the mean annual

PM2.5 concentrations measured ov er a three year period. Th is is referred to as the “design value” and reduces the year to y ear variability. Table 1 provides the 2006 annual standard design values and the annual average values for 2004, 2005, and 2006 for each monitoring site with complete data. The northern portion of the Valley meets the annual PM2.5 standard, as i ndicated by the design values at Stockton, Modesto, and Merced. The highest PM2.5 annual design va lues are located in the southern and central portions of the basin, in cluding Bakersfield and Visalia. Three-Year Average PM2.5 Trend

0 5 10 15 20 25 30 35199019911992199319941995199619971998199920002001Concentrations (ug/m3)

Bakersfield

Fresno-1st Street

Stockton

Visalia5 Table 1. PM2.5 Annual Average C oncentrations and 2006 Design Values

Annual Average (ug/m 3 )

Monitor 2004 2005 2006 2006 3-year Annual Average

Design Value (ug/m 3 )

Clovis-N Villa Avenue 15.8 16.0 16.8 16.2

Bakersfield-410 E Planz Road 17.4 19.9 19.3 18.9

Bakersfield-5558 California Avenue 19.0 17.9 18.7 18.5

Bakersfield-Golden State Highway 18.1 18.9 18.6 18.5

Corcoran-Patterson Avenue 17.3 17.6 16.7 17.2

Fresno-1st Street 16.4 16.9 16.8 16.7

Fresno-Hamilton and Winery 17.0 16.9 17.6 17.2

Merced-2334 M Street 15.3 14.1 14.8 14.7

Modesto-14th Street 13.6 13.9 14.8 14.1

Stockton-Hazelton Street 13.2 12.5 13.1 12.9

Visalia-N Church Street 17.0 18.8 18.8 18.2

Trends in annual PM2.5 design values show t hat considerable progress has occurred in the San Joaquin Valley over the last five y ears (Figure 4). In 2001, all monitoring sites in the Valley had annual desig n values greater than 16 ug/m 3 , with the Visalia site at approximately one and a half times the level of the standard. By 2006, design values decreased throughout the Valley, and only those sites in the southern and central portions of the Valley still have de sign values greater than 16 ug/m 3 . Bakersfield–Planz is the current high site, with a design val ue which is 26 percent above the standard. The greatest rate of progress has occurred in the northern and central basin. These trends underscore the challenge the Valley fa ces in attaining the annual standard in the southern portions of the Valley . The surrounding mountains co mbined with the Valley’s prevalent cold, damp, stagnant winters, create an environment very conducive to PM2.5 formation and buildup, especially in the southern end of the Valley.

Figure 4. Trends in Annual PM2.5 D esign Values in the San Joaquin Valley

Three-Year Annual Average PM2.5 Design Values

0 5 10 15 20 25 30

2001 2002 2003 2004 2005 2006

YearConcentrations (ug/m3) Bakersfield-410 E Planz

Bakersfield-5558 California

Bakersfield-Golden

Modesto-14th Street

Stockton-Hazelton

Visalia-N Church

Fresno-1st Street6 In addition to looking at trends in average concent rations of PM2.5, it is also useful to

look at the trends of the di fferent components that make up PM2.5. As stated earlier, PM2.5 is a complex mixtur e dominated by ammonium ni trate, organic carbon, and ammonium sulfate. Analysis of the trends in the differ ent components of PM2.5 shows

that over the last five years, decreases in carbonac eous aerosols and ammonium nitrate have had the greatest impact on declining PM2.5 levels. In Fresno, carbonaceous aerosols have declined by 37 percent and ammonium nitrate concentrations by 24 percent (Figure 5), wh ile in Bakersfield, carbonaceous aerosols (organic plus elemental carbon) have decli ned by 16 percent and ammonium nitrate concentrations by 23 percent. During this sa me period, PM2.5 and NOx emissions, as
well as NOx levels measured in the air also decreased. Longe r-term records show

concomitant decreases between ambient NOx and ammonium nitrate as well as
between ambient SOx and ammonium sulfate. The combined downward trends in PM2.5 components, precursor concentrations, and emissions all in dicate that the ongoing control program has had substantial benefits in impr oving air quality and that

the reductions from measures in this Pl an will provide continuing progress towards and

attainment of the f ederal PM2.5 standards.

Figure 5

. Trends in PM2.5 Key Chemical Components

.

D. California Regional Particulate Matter Air Qualit y Study (CRPAQS) 1

The California Regional Particulate Air Qua lity Study (CRPAQS) provides the scientific foundation upon which the PM2. 5 SIP planning efforts ar e built. CRPAQS is a collaborative effort between the public and private sector designed to: 1) develop an improved understanding of particulate matter in central California; and, 2) provide

1 http://www.arb.ca.gov/airways/ccaqs.htm Trends in PM2.5 Chemical Components

Fresno-1st

0 2 4 6 8 10 12 14

2001* 2002* 2003 2004 2005 2006Concentrations (ug/m3) Ammonium

Nitrate

Ammonium

Sulfate

Carbonaceous

Aerosols7 decision-makers with the tools needed to identify equitable and efficient control methods. The study is a comprehensive multi- year effort of met eorological and air quality monitoring, emission inventory development, data analysis, and air quality simulation modeling. The study reflects an investment of near ly 27 million dollars, coupled with extensive in-kind support from study sponsors, extending over a 15-year period. The resulting data and analytical tools are providing the most advanced scientific understanding avail able for SIP development.

CRPAQS is intended to evaluate the Valley’s par ticulate matter challenges with respect
to both the federal and Stat e air quality standards for particulate matter smaller

than 10 micrometers in diam eter (PM10) and PM2.5. CRPAQS was designed to address annual particulate levels as well as fall and winter episodic conditions. Numerous teams of experts participated in t he study. Data was collected for 14 months (December 1999 through February 2001) th roughout the Valley and surrounding regions. The extensive field monitoring pr ogram collected data at the surface from hundreds of monitoring sites located th roughout the study domain, and aloft with appropriately equipped air planes , blimp, specialized balloons, and towers (Figure 6).

The effort resulted in millions of data reco rds which have been housed in a world class data base. Focused efforts have also improv ed the emission inventor y for the region. Finally, state-of–the-science air quality models have bee n tested with the extensive
CRPAQS data base and are used in t he CRPAQS and SIP modeling tasks.

Figure 6. CRAPQS M onitoring Program8 II. AIR QUALITY PLANNING

A. Air Quality Planning Background

The federal Clean Air Act Amendments of 1990 (Act) establish the planning requirements for those areas that routinely e xceed the health-based NAAQS. These nonattainment areas must adopt and implement a State Implementation Plan (SIP) that demonstrates how they will attain the standards by specified dates. Federal law holds each state responsible for impl ementing the provisions of the Act. California law assigns air quality planning responsibilities with in the State. In t he San Joaquin Valley, those responsibilities are shared among the S an Joaquin Valley Air Pollution Control District (District), the Valley’s metr opolitan planning organizations, and the Air Resources Board (ARB).

In the air quality management process, m any regulatory agencies in California work together to reduce air pollution levels. Ea ch of these agencies is responsible for achieving emission reductions from a part of the inventory. ARB has primary regulatory authority over California’s m obile sources, fuels, and consumer products. U.S. EPA sets new engine standards for sources includi ng large farm and construction equipment and locomotives. Air districts have primar y authority over stati onary emission sources, including industrial and commercial equipme nt and area sources. The metropolitan planning organizations are responsible for developing the regional transportation plans

that are used to estimate mobile source em issions. These transportation plans can also impact land use patterns, and the availability and attractiveness of transit alternatives.

The air districts develop and adopt local air qua lity plans. In this case, the District approved the SJV 2008 PM2.5 Plan on April 30, 2008. U pon approval by the ARB, SIPs are submitted to U.S.EPA for approv al. Once approved by U.S. EPA, SIPs

become enforceable.

B. Recent Air Quality Planning

Over the past decade, the District and AR B have adopted a series of regulations and measures to improve air quality in the Valley. New mobile source requirements, cleaner fuels, and multiple consumer products regulations have been adopted and are being implemented today. And, while California continues to face serious air quality challenges, it is important to recognize t he progress made as a result of California’s landmark air pollution control programs.

The District has implemented a successful PM 10 attainment plan which has resulted in the Valley coming into attainment of the federal PM10 standard. U.S. EPA concurred

with the District’s attainment assessmen t, and on March 19, 2008, published a final

affirmation of attainment of the PM10 standard for the Valley 2 . In addition, on

2 Federal Register: March 19, 2008 (Volume 73, Number 54, pages 14687-14713)9 April 25, 2008 3 , U.S. EPA proposed approval of the Dis trict’s plan to maintain the PM10

standard.

On April 2007, the District adopted the 2007 Oz one Plan. The ozone plan charts the

course to attainment of the federal 8-hour ozone NAAQS in the Valley. ARB approved the ozone plan and submitted it to U.S. EPA as a SIP revision . Many of the measures in the PM10 and ozone plans are providing pr ogress towards attainment of the PM2.5

standards.

On September 27, 2007, ARB adopted the 2007 State Strategy to achieve new emission reductions needed to bring areas of the State into atta inment of both the federal PM2.5 and ozone air qua lity standards. The commitment for 2014 in the State Strategy includes reductions needed to attain the PM2.5 standards and provide progress towards meeting the ozone standard.

C. General Planning Requirements

On April 25, 2007, U.S. EPA finalized it ’s implementation rule for PM2.5 4 . The rule outlines the planning elements that the PM2.5 SIP must address. These include:

• base year and future year emission in ventories for manmade sources of air pollution in the nonattainment area;

• air quality modeling that demonstrates attainment of the PM2.5 standards as expeditiously as practicable;

• weight of evidence - supplemental analys is of air quality, emission data, and trends supporting the primary model ed attainment demonstration;

• control strategies capable of meeting attainment;

• reasonable further progress (RFP) plan;

• contingency measures in the event the c ontrols fall short of achieving needed reductions;

• demonstration that all reasonably ava ilable control technology (RACT) and reasonably available control measures (RACM) have been applied to existing

sources;

• transportation conformity emission budget s to ensure transportation plans and projects are consistent with the SIP; and

• commitment for mid-course review.

3 Federal Register: April 25, 2008 (V olume 73, Number 81, pages 22307-22318

4 Federal Register: April 25, 2007 (Vol ume 72, Number 79, pages 20586-20587)10 III. PLAN EVALUATION

A. Overview of the San Joaquin Valley PM2.5 Plan

The SJV 2008 PM2.5 Plan provides the tech nical foundation and control strategy for attaining the federal PM2.5 standards. The Plan demonstrates the Valley will attain the standards as expeditiously as practicabl e, no later than the 2014 deadline.

The Plan consists of adopted measures that provide increasing benefits each year, along with new emission reduction commitment s from both ARB and the District. The Valley’s particle pollution problem is well st udied as a result of the $27 million invested in the California Regional Particulate Matter Study. This study provides the scientific foundation for the PM2.5 SIP by identifying the pollutants most important to formation of PM2.5 pollution. The results indicate that the key pollutants to reduce are NOx, SOx, and directly emitted PM2.5 particles. The Plan addresses these three pollutants consistent with U.S. EPA guidanc e. Emissions of VOC are also being reduced in the region as part of the ozone attainment stra tegy but are not required to be included in
this SIP.

Overall, between 2005 and 2014, NOx emissions will decrease by almost 300 tons per day (tpd), direct PM2.5 emissions by over 20 tpd, and SOx by almost 3 tpd. Two thirds
of the NOx and SOx re ductions and one half of the PM 2.5 reductions come from already adopted measures. A significant po rtion of the new commitments come from the ARB’s State Strategy t hat was adopted in September 2007. The State Strategy provides an additional 76 tons of NOx reductions and 5 tons of PM2.5 reductions in
2014. The District has accelerated several measures in its 2007 Ozone Plan that are also part of the PM2.5 attain ment strategy, and targeted a number of categories of

PM2.5 for additional emissi on reductions, including resi dential wood burning and commercial cooking. Past District effo rts to reduce impacts from residential wood burning have proven to be very effective, and continued reductions in this source category are expected to contribute si gnificantly to further progress.

As emissions have decreased each year, th e entire Valley alr eady meets the daily standard and parts of the Valley are already attaining the annual standard. The air quality modeling indicates that attaining the annual standard in the southern Valley is the biggest challenge, but all areas are projected to atta in the standard by 2014. The Plan will also bring the region much clos er to meeting a new federal PM2.5 standard that will apply to future SIP planning effo rts. SIP planning for the newer standard will occur after U.S. EPA designates nonattain ment areas and develops implementation

rules.

ARB staff has reviewed the 2008 PM2.5 Plan and the District’s technical analysis and agrees that the Plan meets federal requirem ents. The following sections describe the major elements of the Plan.11 B. Emission Inventory

An emission inventory consists of a systemat ic list of the sources of air pollutants with an estimate of amount of pollutants from each source or source category over a given period of time. The inventories used in this Plan were developed using the most recent planning assumptions and the best av ailable technical information.

Air quality plans rely on emission inventories to help identify sources to control and as inputs to the photochemical m odels required for attainment demonstrations. Planning inventories which are aggr egated by source type and inventory sector focus on anthropogenic sources and are express ed as annual average day and average seasonal day. In the case of PM2.5, ambient concentrations are highest in the winter so the planning inventory includes an estimate of average winter day emissions. This helps planners identify what source categories have the hi ghest emissions during those periods when the PM2.5 ambient values are highest. Mode ling inventories include both emissions from human activities (anthr opogenic sources) and from natural sources (non-anthropogenic sources). Emissions ar e both spatially distributed geographically and represent hourly estimates for each grid ce ll in the modeling domain. The emission

estimates also include the effect s of climatic factors such as temperature and humidity. The models relate current air quality to cu rrent emissions levels of PM2.5 and its precursors, and simulate future air quality based on changes to the emissions as the

result of new control measures. The curr ent or baseline inventories used in the Plan reflect District and ARB controls adopted through 2006 and assume an estimated 24 percent growth in population and 14 percent growth in vehi cle miles traveled in the estimated future year inventories. Ba seline inventories do not include potential
reductions from the new District measures identified in the SJV 2008 PM2.5 Plan or ARB measures in the adopt ed 2007 State Strategy.

1. Estimating Emissions

In California, computer m odels developed by ARB are used to estimate the emissions
from on- and off-road mobile sources. St ationary source emissions estimates are developed by the Districts and derived from permit data. Area- wide emissions are

estimated based on emission factors and info rmation on expected activity from these

diverse sources. Area-wide and off-road so urce emissions are estimated by ARB and the District. Emission inventories undergo r outine reevaluation to ensure that they remain up to date and accurate.

Emission estimates used in the SJV PM2.5 2008 Plan take into account emission data, expected growth in activity, and ARB r egulations and District rules adopted by

December 2006. Mobile source emission inv entories used in the Plan were developed using EMFAC2007, California's on-road mo tor vehicle emission factor model and
OFFROAD2007 for emissions from mobile off-road vehicles and equipment. Transportation activity data was provided by the eight Valley Councils of Government (COGs) from their Regional Transportation Plans.12 The District worked with ARB staff to update emission estimates from stationary and area source categories for which new and improved data became available. Improvements targeted the day-specific m odeling inventory as well as the annual and winter planning inventories. Annual and winter planning inventory adjustments included District methodology revisions and impacts of adopted rules (e.g., open burning, wood burning fireplaces and heaters, cooking, manufacturing and industrial fuel combustion). A summary of a major District revision, as well as ARB updates follows:

 Non-point source manufacturing and industrial natural gas combustion

. District staff refined the methodology for esti mating emissions from industrial natural gas combustion sources that are too small to fall into the District’s permitting program. Using data from the California Energy Commission on natural gas deliveries, District staff estimates 2005 NOx emissions ar e 25 tpd less that previously estimated and in 2014 they are 29 tpd less.

 PM2.5 size fractions for fugitive dust sources

. ARB staff updated the estimates of dust in the PM2.5 size fraction based on PM size fraction profiles developed by the West ern Regional Air Partnership (WRAP) 5,6 and PM2.5/PM10 ratios obtained from air quality m easurements in California. Previously used profiles for dust emitting cat egories (e.g., paved and unpaved roads, construction and demolition, agricultural tilli ng) overestimated the amount of dust in

the PM2.5 size fraction.

 Paved Road Dust
ARB staff refined PM2.5 emission estimate s from paved road dust by subtracting PM2.5 emissions from vehicle exhaust, tire wear, and brake wear to avoid double counting. These emissions are already ac counted for in the on-road motor vehicle emission inventory. In additi on, ARB staff revised the ra te at which emissions are grown from the base year to a future year to reflect projected lane miles of new road.

2. Summary of Baseline Emissions

Emission sources in the San Joaquin Valley ar e diverse. The San Joaquin Valley is an important transportation corridor for moving goods and people inside the State and beyond. In addition, it is one of the most pro ductive agricultural regions in the world, as

well as home to industrial and commercial activi ties. All of these sources contribute to the concentrations of pollu tants in the Valley.

The following discussion focuses on the annual planning inventory used in the SJV 2008 PM2.5 Plan. Appendix B of the SJV 2008 PM2.5 Plan includes detailed

5 Cowherd, C. Analysis of the Fine Fraction of Particulate Matter in Fugitive Dust , Final Report. October 12, 2005. Midwest Research Institute. MRI Project No. 110397. phttp://www.wrapair.org/forums/dejf/document s/fffd/Final_Fractions_Dust_Report.pdf

6 Cowherd, C., Proposed Revisions to Fine Fracti on Ratios Used for AP-42 Fugitive Dust Emission Factors. November 7, 2005. Midwest Re search Institute. MRI Project No. 11039713 annual average and winter average daily planni ng inventories for directly emitted PM2.5, and the precursors NO x and SOx for 2005 and for each y ear from 2009 to 2014.

Table 2 lists the baseline annual planning inventory for 2005 and 2014 for directly emitted PM2.5, NOx, and SO x precursors in the San Joaquin Valley in 2005 and emissions projected for the 2014 attainment year split by source category.14 Table 2. San Joaquin Valley Air Basin

Baseline Emission Trends a,b
(Annual Planning Inventory in tons per day, tpd)

Source Category

Pollutant Emissions Stationary

and AreaWide On-Road

Vehicles Off-Road

Vehicles

and Equipment Total b

2005 (tpd) 64.9 12.1 9.0 86.0

2014 (tpd) 59.5 8.9 6.6 75.0

Change

(tpd) -5.4 -3.2 -2.4 -11.0 PM2.5

Change (%) -8% -26% -27% -13%

2005 (tpd) 93.6 327.9 153.9 575.4

2014 (tpd) 67.3 206.7 102.2 376.2

Change

(tpd) -26.3 -121.2 -51.7 -199.2 NOx

Change (%) -28% -37% -34% -35%

2005 (tpd) 21.3 2.6 2.4 26.4

2014 (tpd) 22.9 0.7 0.8 24.5

Change

(tpd) +1.6 -1.9 -1.6 -1.9 SOx

Change (%) +7% -73% -67% -7%

a. Baseline emissions include State control meas ures and District contro ls adopted through 2006. b. Numbers may not add up exactly due to rounding.15 In summary, baseline PM2.5, NOx, and SOx em issions from all sources in the Valley show an overall downward trend due to already adopted regulations and programs. The slight increase in SOx fr om stationary sources is addre ssed in the Plan. Although

motor vehicle miles traveled in the basin continue to increase, on-road vehicle emissions are dropping because of more stri ngent vehicle emission standards and fleet turnover. This trend will be strengt hened between 2005 and 2014 as newer, loweremitting vehicles become part of the fleet.

C. Air Quality Modeling

Air quality modeling guides the selection of t he most effective pollutants to control and the magnitude of emission reductions needed from each of the pollutants. U.S. EPA’s modeling guidance requires the use of air q uality modeling to relate current PM2.5 levels to emissions (of PM2.5 and PM2.5 pr ecursors) and meteorology in a region, and to simulate future air q uality based on changes in emissions. PM2.5 air quality modeling uses day-specific grid-based em ission inventories and meteorological measurements to establish this relationship. Model predictions combined with observed
concentrations of PM2.5 and its individual components provide the foundation for the
U.S. EPA-recommended attainment demonstr ation (Speciated Modeled Attainment Test). Rather than using air quality m odel predicted PM2.5 concentrations results directly, U.S. EPA Guidance calls for usi ng models in a relative sense to develop relative response factors (RRFs) for each of the PM2.5 chemical species. The RRFs

are calculated as the ratios of the future -year to reference-year model-simulated concentrations of PM2.5 species at a spec ific location. The impact that emission reductions have on the future-year model ed PM2.5 species is assumed to be proportional to the impact on t he base-year PM2.5 design val ue. The attainment test provides reconciliation between speciat ed and bulk mass concentration measurements,

and is the basis for a connection between obse rvations, modeled PM2.5 concentrations, and the air quality standard.

ARB staff conducted the grid-based photochemical modeling used in the SJV 2008 PM2.5 Plan with input from the Di strict. The modeling analysis is based on data acquired from the $27 m illion state-of-the-science CPRAQS study. Modeling procedures followed U.S. EPA gui delines. A brief summary is provided below with more information on the air quality m odeling conducted by ARB staf f in Appendix A to this report and Appendix F of the SJV 2008 PM2.5 Plan.

1. Grid-based Photochemical Modeling

Grid-based photochemical mode ling supports attainment demonstrations of the annual

and the 24-hour PM2.5 standards in the San Joaquin Valley. The modeling platforms and chemical mechanism used in the photochem ical modeling are summarized below.

U.S. EPA’s Community Multiscale Air Qualit y Modeling System (CMAQ) was selected to simulate air quality in the San Joaquin Valle y. CMAQ is a stat e-of-the-science “oneatmosphere” system that treats major atmo spheric and land processes and a range of16 species in a comprehensive framework. CMAQ has been extensively peer-reviewed and is well documented. A meteorologica l model, the Mesoscale Model version 5 (MM5), was used to generate the meteorologica l fields for the CMAQ model. Modelers chose the most up-to-date and comprehensiv e chemical mechanism (SAPRC99) along with CMAQ aerosol code version 4 and aque ous phase chemistry to simulate the complex mixture of PM2.5 spec ies in the San Joaquin Valley.

CMAQ was run for the year 2000 to provi de the basis for the model performance evaluation. It was during 2000 that the CRPAQ S took place. The study resulted in a wealth of data with which to evaluate model per formance. As it is necessary to execute simulations for a model reference year and a future year to perform the recommended modeled attainment demonstration, 2005 and 2014 were also simulated. Simulations for all years were driven by the meteorolog ical inputs for 2000, while emissions varied from year to year. Meteor ological conditions during 2000 were very conducive to the
formation and accumulation of PM2.5.

As recommended by U.S. EPA, the SMAT pr ocedure was applied to Federal Reference Monitors (FRM) operating in the San Joaqui n Valley. The 2006 design value (average of the 2004, 2005, and 2006 annu al average PM2.5 concentrations) was used as a basis from which to project estimated futu re year design values for the year 2014 (average of the 2012, 2013, 2014 annual average PM2.5 concentrations). Speciation of
the FRM mass was based on data from the S peciated Trends Network (STN) sites in the Valley and on analysi s of CRPAQS data.

The attainment demonstration for t he annual standard required modeling PM2.5 concentrations for each day of the referenc e year (2005) and future year (2014). The

attainment demonstration for the 24-hour PM2.5 st andard used only the top 25% of the measured and modeled days for each quarter instead of all available days.

ARB staff evaluated air quality model and me teorological model performance based on U.S. EPA guidance and other related methods in the published academic literature. As noted above, model performance evaluation benefited from use of the extensive CRPAQS data set, ensuring a robus t modeling simulation.

2. Weight of Evidence

The Weight of Evidence (WOE) analysis provi des a set of complementary analyses that supplement the SIP-required photochemical modeling. A WOE appr oach looks at the entirety of the information at hand to provide a more inform ed basis for the attainment strategy. Because all methods have inheren t strengths and weaknesses, examining an air quality problem in a variety of ways offs ets the limitations and uncertainty that are inherent in photochemical modeling. This approach also provides a better understanding of the overall problem and the level and mix of emissions controls

needed for attainment.17 Appendix H of the SJV 2008 PM2.5 Plan includes the initia l draft of the WOE analysis. Appendix B of this staff r eport updates this analysis and summarizes the analyses that comprise the WOE assessment for the San Joaquin Valley. ARB staff evaluated air quality and emission trends; observational model results, including those of source receptor models, such as chemical mass balance (CMB) and positive matrix factorization (PMF); and evaluated diagnostic indicator species results. Along with the results from the photochemical modeling, District staff conducted a rollback modeling analysis to estimate the impacts of future emission reductions on resulting air quality. Rollback modeling combines source recept or model results wit h predicted emission inventory data that include emission r eductions from adopted and proposed control

measures to estimate future PM2.5 concentra tions. Source receptor models use data on the concentrations of chemical species m easured in ambient PM2.5 to identify the contributing sources. An extensive discussion of the ro llback methodology and the results are provided in Chapter 3 of the SJV 2008 PM2.5 Plan.

3. Demonstrating Attainment

Modeling was used to establish emission redu ction targets for developing the control strategy in the Plan. ARB staff used photochemical modeling to verify that the proposed control strategy would result in attainm ent of the PM2.5 standar ds throughout the basin
in 2014. The emission reductions needed fr om new control measures to reach attainment throughout the Valley in 2014 are summarized in Table 3:

Table 3. Emissions and Emission Reductions a (annual average emissions in tpd)

Direct PM2.5 NOx SOx

2014 Baseline Emissions 75.0 376.2 25.6

2014 Control Measure Emission
Reduction Commitments 12.7 85.0 0.9

2014 Attainment Emissions 63.3 291.2 24.5

a. Numbers may not add up exactly due to rounding.

As mentioned earlier, based on 2004-2006 data, the Valley already meets the federal 24-hour standard. Modeling results for the five sites with highest 2006 design values show that further emission controls will result in even lower 24-hour design values in 2014 (Table 4), ensuring continued progr ess towards the strengthened 24-hour standard which will be addressed in future planning efforts.18 Table 4. Reference and Future Year 24-hour Design Values (DV) a (micrograms per cubic meter, μg/m 3 )

Site 2006 DV 2014 "Controlled" DV

Bakersfield - California 62.4 46.2

Bakersfield - Planz 65.2 45.9

Bakersfield - Golden 64.4 45.3

Fresno - 1st Street 58.0 41.2

Fresno - Hamilton 58.5 41.7

a. Design values equal to or below 65.4 μg/m 3 meet the annual PM2.5 NAAQS.

Modeled design values demonstrate the San Joaquin Valley will attain the annual
PM2.5 federal standard in 2014 at all monitori ng sites (Table 5). The 2014 design value is the three-year average of modeled 2012, 2013, and 2014 values. For comparison, Table 5 also lists the 2006 design val ues calculated from measured PM2.5 concentrations and the impact of baseline em ission reductions on modeled 2014 design

values. Baseline emission reductions due to already adopted rules provide from 58 to 63 percent of progress towards attainment. Sites in the northern and central Valley would be expected to attain the standard in 2014 with baseline emission reductions.
With the addition of the new State and local measures, the sites with the most severe problem – Visalia and Bakersfield – would also attain in 2014, with a maximum design

value of 14.7 in Bakersfield. The linear rollback analyses showed similar results, providing a consistent assessment of atta inment prospects. Modeling analyses also

show that annual PM2.5 concentrations are more sensitive to reductions in directly emitted PM2.5 as compared to NOx in 2014. On average, reducing 1 tpd in PM2.5 emitted from combustion activities is approx imately 9 times more effective than reducing 1 tpd of NOx.19 Table 5. Reference and Future Year Annual Design Values a (μg/m 3 )

Site 2006 DV 2014 Baseline DV 2014 "Controlled" DV

Bakersfield - California 18.51 15.86 14.28

Bakersfield - Planz 18.86 16.26 14.70

Bakersfield - Golden 18.64 15.98 14.39

Clovis 16.39 14.10 12.72

Corcoran 17.24 14.75 13.27

Fresno - 1st Street 16.68 14.43 13.01

Fresno - Hamilton 17.16 14.93 13.47

Merced 14.69 12.85 11.76

Modesto 14.10 12.52 11.44

Stockton 12.93 11.77 10.87

Visalia 18.20 16.05 14.47

a. Design values equal to or below 15.04 μg/m 3 meet the annual PM2.5 NAAQS.

The weight-of-evidence analyses provide a cons istent assessment th at the San Joaquin Valley will attain the annual average PM2. 5 standard throughout the Valley in 2014. Significant progress has al ready occurred, a 6 ug/m 3 drop in annual average design value between 2001 and 2006, whic h represents two-thirds of the progress needed to attain the annual standard by 2014. Ammonium nitrate, ammonium sulfate, and carbon concentrations have responded positively to pas t reductions in NOx, SOx, and primary
PM2.5 emissions. Substantial future emission reductions will occur due to both

baseline commitments as well as new m easures from NOx, and primary PM2.5 emissions that have worked in the past. Linear rollback analysis indicates attainment in 2014. Grid-based aerosol modeling also indica tes attainment in 2014 at all sites in the District. However, attainment is expected to phase in starting in the northern portion of the Valley and spreading south, with more and more areas reaching attainment as we move towards 2014. As mentioned earlier, the mountains surrounding the Valley act as air flow barriers, with the resulting stagnant conditions favoring the accumulation of emissions and pollutants, making it harder for the southern por tion of the Valley to reach

attainment sooner.

4. Attainment Date

The Act requires nonattainment areas to attain the PM2.5 st andards as expeditiously as practicable beginning in 2010, but no later than 2015. U.S. EPA guidance sets 2014 as the practical deadline for SIP planning purpo ses by requiring that the necessary emission reductions be achieved one year earlier. As required, t he Plan identifies the proposed attainment date based on the se verity of the PM 2.5 problem and the availability and feasibility of c ontrol measures in the region. The District determined that

feasible controls were not available to atta in achieve the necessary emission reductions
earlier than 2014. The State requests U.S. EPA approve Ap ril 5, 2015 as the deadline20 consistent with its guidance t hat the SIP must provide for the necessary emission reductions by 2014. The request is based on:

 the magnitude of the rema ining PM2.5 challenge in t he San Joaquin Valley, as reflected by monitoring data;

 the significant amount of emission reduc tions required for reaching attainment

o by 2014, on-going control programs will reduce direct PM2.5 emission by 13% from 2005 emission levels. To reach attainment, new measures

need to reduce direct PM2.5 emissi ons by an additional 15%, plus

o on-going control programs will reduce NOx emission by 35 % from 2005 emission levels. New measures need to reduce NOx emissions by an additional 15% to reach attainment; and

 the control strategy in the SJV 2008 PM2.5 Plan incl udes the District and State

control measures that are available and fe asible within the proposed attainment

timeframe.

Considering the following factors, 2015 is iden tified as the earliest feasible attainment date: 1) baseline emission r eductions that occur during the period up to 2014 are not sufficient alone to provide for attainment at all sites, and 2) the additional emission reductions resulting from the State Strategy will not phase in prior to 2014 due to the extraordinarily complex and in novative nature of developing and implementing these

new measures.

ARB staff concurs with the District’s a ssessment of the most expeditious and practicable attainment date fo r the San Joaquin Valley. As mentioned in the previous section, the results of t he modeling and weight-of-evidenc e analyses, which include the impacts of control measures available and feasible at the District and State levels show the San Joaquin Valley will attain the PM2.5 standards in 2014.

D. Control Strategy

The SJV 2008 PM2.5 Plan inte grates the NOx strategies adopted as part of the 2007 Ozone Plan. Among the guiding principles for developing the control strategy, the District gives precedence to NOx, which is also an ozone precursor. However, recognizing the importance of directly emitted PM2.5, addi tional measures to address this component have also been included. Dir ectly emitted PM2.5 emission reductions are approximately nine times more effective than NOx reductions in the attainment year Overall, between 2005 and 2014, NOx emissions will decrease by almost 300 tons per day, direct PM2.5 emissions by over 20 tons per day, and SOx by almost 3 tons per day. Two thirds of the NOx and SOx reducti ons, and one half of the PM2.5 reductions come from already adopted measures. Fi gure 7 below illustrates the continuous progress in reducing NOx and PM2.5 emissi ons on the path towards attainment by

2014.21 Figure 7

1. New District Measures

a. Rule Development Commitment

The Valley’s approved PM2.5 Plan contains the District’s commitment to develop and implement a suite of control measures fo r NOx, direct PM2. 5, and SOx that in aggregate will achieve the total emission reducti ons specified in Table 6. Table 6 lists the 8 quantified measures, emission reduction s in each reasonable further progress and attainment milestone year s (2009, 2012, and 2014), and rule adoption timelines. By 2014, the District measures will reduce emi ssions by 9.0 tons per day of NOx, 6.7 tons per day of PM2.5, and 0.9 tons per day of SOx. Some of these measures may provide for additional emission reductions from other pollut ants which are not quantified at this time. In addition, Table 7 lists 5 c ontrol measures for which the District has not specified emission reductions because work is currently underway to due to refine the emission inventory and assess current control efficiency. The District expects these

measures to realize further emission reducti ons. All measures are to be developed by 2010, with implementation no later than 2012. The Plan shows attainment without the potential benefits of the measures.

The SJV 2008 PM2.5 Plan includ es the 6 NOx control rules previously approved in the
2007 Ozone Plan. The District has accelera ted adoption and implemen tation of one of the control measures. In addition, the District has added a new NOx control measure based on equipment attrition. The District has also made progress on two of the feasibility study measures from the Ozone Pl an so that these are now control measures

in this Plan. Countdown to Attainment Levels

0 50 100 150 200 250 300 350

2005 2009 2012 2014Emission Reduction Needed (tpd)

NOx PM2.5 All SIP reductions

achieved22Table 6Summary of District Emission Reduction Commitments in the 2008 PM2.5 Plan(Annual Average Planning tons per day)Projected Reductions by YearCM#MeasureNameCompletionDateComplianceDateReductionStart2009 2010 2011 2012 2013 2014S-COM-5Stationary GasTurbines2007 3Q 2012 2012NOx0 0 0 2.21 2.21 2.21NOx0 0 0 1.49 1.50 1.52PM2.50 0 0 0.23 0.24 0.24S-COM-1Boilers, SteamGenerators andProcess Heaters(>5 MM Btu/hr)2008 3Q 2012 2012SOx0 0 0 0.76 0.76 0.76S-COM-7Glass MeltingFurnaces2008 3Q 2009 2009NOx1.22 1.25 1.18 1.60 1.67 1.58S-COM-9ResidentialWater Heaters2009 1Q Attrition 2011NOx0 0 0.20 0.25 0.32 0.40S-IND-9CommercialCharbroiling2009 2Q 2011 2011PM2.50 0 2.17 2.21 2.25 2.28NOx00.040.080.070.070.06PM2.50 0.39 0.76 0.73 0.71 0.69S-COM-14Wood BurningFireplaces andWood BurningHeaters2009 3Q 2010 2010SOx0 0.01 0.02 0.02 0.02 0.02S-COM-3Boilers, SteamGenerators andProcess Heaters(0.075 to <2MMBtu/hr)2009 4Q 2011 2011NOx0 0 0.12 0.27 0.39 0.55NOx1.21 1.95 2.68 2.67 2.66 2.65PM2.51.60 2.57 3.53 3.52 3.50 3.49S-AGR-1 Open Burning 2010 2Q 2010 2009SOx0.06 0.10 0.14 0.14 0.14 0.14TOTAL NOx REDUCTIONS2.433.244.268.568.828.97TOTAL PM2.5 REDUCTIONS1.602.964.466.696.706.70TOTAL SOx REDUCTIONS0.06 0.11 0.16 0.920.920.9223 Table 7. Implementation Schedule of Additional District Control Measures

CM# Measure Name Completion

Date Compliance

Date Reduction
Start

S-COM-2 Boilers, Steam Generators

and Process Heaters (2 to 5 MMBtu/hr) 2008 3Q 2012 2012

S-IND-21 Flares 2009 2Q 2010 2010

M-TRAN-1 Employer Based Trip Reduction Programs 2009 4Q 2012 2011

S-COM-10 Natural Gas-Fired, Fan Type
Residential Central Furnace 2010 2Q Attrition 2012

S-COM-6 Reciprocating Internal Combustion Engines 2010 4Q 2012 2012

The SJV 2008 PM2.5 Plan also identifies 11 future study measures, which upon completion, could result in opportunities for additional emission reductions. These study measures seek to explore where and how addi tional reductions may be achieved in the future. The District is committing to release study reports by the dates listed in Table 8 and to incorporate additional meas ures identified as fruitful in future PM2.5 plans. The Plan shows attainment without the potent ial benefits of these measures.

Table 8. District Stationary Source Feasibility Study Implementation Schedule

CM# Measure Name Completion

Date

S-AGR-2 Conservation Management Practices 2010

S-COM-4 Solid Fuel Boilers Steam Generators, Process Heaters 2009

S-COM-6A Small Spark-Ignited Engines and Agricultural Spark-Ignited Engines 2008

S-COM-8 Lime Kilns 2011

S-COM-11 Dryers 2011

S-GOV-6 Prescribed Burning 2008

S-IND-8 Cotton Gins 2009

S-IND-4 Fugitive PM10 Prohibitions (Regulation VIII) 2009

M-OTH-8 Indirect Source Review (ISR) Enhancement 2010

M-OTH-9 Healthy Air Living TBD

M-OTH-10 Fireworks 201224 ARB staff reviewed the District’s rule development commitments and considered comments received regarding fu rther opportunities for emission reductions. On a case-by-case basis, staff considered emissi on sources, their distribution in the San Joaquin Valley, and the applicability of emission contro l approaches to the different types of sources. A summary of staff’s findings for specific s ource categories follows:

Glass Melting Furnaces The Plan includes rule development commi tment S-COM-7 with adoption scheduled in the third quarter of 2008. The District has already released a draft rule for public comment and held a public workshop on Februar y 8, 2008. As currently proposed, the rule would result in greater NOx reducti ons than those estimated in the Plan for S-COM-7, as well as those ci ted in public comments.

Internal Combustion (IC) Engines The District’s current rule for IC engines is comparable to other IC engine rules in
California. The Plan includes rule development commitment S-COM-6 for non-agricultural (non-ag) IC engines, with adoption scheduled in the fourth quarter of 2010. In the ozone plan, S-COM-6 was listed as a feasibility study to be completed in 2012. In addition, the Plan includes feasibili ty study S-COM-6A for agricultural (ag) IC engines to be conducted in 2008. The District is considering the more stringent South Coast IC Engine Rule 1110.2 which sets requirements in common for both ag and nonag IC engines, but applies to very few ag IC engines. The cost-effectiveness and feasibility of electrifying all engines will ne ed to be carefully evaluated with consideration of the availability of electricity in some of the more rural areas in the Valley.

Dryers The District recently adopted a rule for large dr yers. In the Plan, t he District commits to further studying control options for small dr yers in 2011 (feasibility study S-COM-11). Existing control technology may not be applicabl e to all small dryers. The South Coast Ozone/PM2.5 Plan includes a pr oposed control measure for sm all dryers, but considers that pursuing emission reductions as part of a measure requiring facilities to modernize equipment and processes with materials comply ing with the best available controls

would be a better fit.

Large Boilers - rated 5 MMBTU/HR and above The Plan includes rule development commitm ent S-COM-1 with adoption in the third quarter of 2008. The District has already re leased a draft rule for public comment and held a public workshop on March 1, 2008. The draft rule sets NOx emission limits which can be met with Selective Catalytic Reduction or ultra-low NOx burners. As proposed, rule implementation would result in greater reductions than those estimated

in the Plan.

Medium Boilers-rated 2-5 MMBTU/HR The Plan includes rule development commi tment S-COM-2 with adoption scheduled in the third quarter of 2008. The District has already released a draft rule for public comment and held a public workshop on Ma rch 17, 2008. The draft rule proposes25 removing the exemption for school boilers by initially controlling them through an incentive funding program.

Small Boilers-rated 0.75-2 MMBTU/HR The Plan includes rule development commi tment S-COM-3 with adoption scheduled in the fourth quarter of 2009. The District is considering accelerating the replacement of old units by 5 percent and expl oring electrification. In the ozone plan, S-COM-3 was listed as a feasibility study to be completed in 2010.

Solid Fueled Boilers The Plan includes feasibility study S-COM-4 to be conducted in 2009. The Valley sources currently operate with selective non-ca talytic reduction with ammonia injection.

The District will consider emission limits in the Sacramento AQMD ru le, as previously recommended by ARB staff, and will evaluate t he applicability of Selective Catalytic

Reduction.

Prescribed Burning The San Joaquin Valley’s existing Sm oke Management Program does not allow agricultural field burns to occur when air qua lity is forecasted to be unhealthy. The Plan includes feasibility study S-GOV-6 to be comp leted in 2008. As part of the study, the District will analyze incentive options and will examine alternatives to burning.

Wood Burning Fireplaces a nd Wood Burning Heaters The Plan includes rule development co mmitment S-COM-14 wit h adoption scheduled in the third quarter of 2009. The District is cons idering strengthening the rule by lowering

the threshold of their mandator y curtailment program . The current rule has been pivotal in reducing the PM2.5 impacts of residential burning and key to the Valley attaining the
federal PM10 standard.

Other suggestions were to also address VO Cs and fugitive dust control measures. However, reductions in VOC emissions are not effective in reducing PM2.5 concentrations in the Valley. Photochemic al modeling analyses conducted in support of the Plan show that the secondary organic co mponent contributes less than 0.5 percent to the organic carbon fraction of PM2.5. In addition, more recent precursor sensitivity analyses show that ammonium nitrate formation is not VOC, but rat her NOx limited. As mentioned earlier, chemical co mposition analyses of ambi ent air quality monitoring samples show that dust is a small component of measured PM2.5 and therefore, dust

controls would not be effective in accelerati ng PM2.5 attainment. However, it remains useful to conduct feasibility studies to gather better information on dust emitting

sources.

b. Incentive-based Strategies

In the attainment demonstr ation, the SJV 2008 PM2.5 Pl an also includes emission

reduction benefits of District incentive programs for which funding has been secured. As part of the 2007 Ozone Plan, the District co mmitted to specific incentive-based NOx reductions in 2012, 2020 and 2023. The SJV 2008 PM2.5 Plan takes credit for the26 2012 emission reduction commitment of 1.4 t pd NOx. These emi ssion reductions are funded through a combination of Indirect Source Review fees, Developer Mitigation Contract fees, and Department of Motor Vehi cle Surcharge fees. Carl Moyer Program reductions are not credited here, as they are included in the ARB baseline emission adjustments.

In addition, the District lists potential future incentive funding that can be used for air quality programs and may lead to “SIP creditable” emission r eductions. Among these is the Proposition 1B: Goods Movement Emission Reduction Program. On February 28, 2008, ARB approved t he first distribution of t he funds under this program.

2. Adopted State Strategy

Cleaning up the mobile source NOx and PM2. 5 sources is the most critical component
of the State’s emission cont rol effort to reduce PM2.5 c oncentrations in the Valley. Vehicles and equipment operating in California are subject to the most stringent tailpipe

emission standards in the world. ARB has a long history of adopting successful programs to reduce emissions from mobile s ources. These regulations will result in fewer emissions as vehicles and equipm ent units meeting the cleanest emission standards enter into service. However, t he benefits of these clean est engines are only realized as new engines enter service and ol der engines are retired, and diesel engines have very long useful lives.

On September 27, 2007, ARB adopted the 2007 State Strategy to achieve new emission reductions needed to bring areas of the State into atta inment of both the federal PM2.5 and ozone air qua lity standards. The commitment for 2014 in the State Strategy includes reductions needed to attain the PM2.5 standards and provide progress towards meeting the ozone standard. The San Joaquin Valley is relying on NOx, SOx, and direct PM2.5 emissi on reductions for PM2.5 attainment.

Table 9 summarizes the estimated benefits fo r 2014 in the San Joaquin Valley from the mix of concepts in the 2007 Stat e Strategy. The potential emi ssion reduction benefits of individual measures are provided for informati onal purposes only. Additional details on

the individual measures are available in the 2007 State Stra tegy, which is available online at: http://www.arb.ca.gov /planning/sip/2007sip/2007sip.htm27 Table 9. Expected Emission Reducti ons from 2007 SIP State Strategy (tons per day)

San Joaquin Valley -- 2014

Proposed New State SIP Measures NOx ROG Direct

PM2.5 SOx

Passenger Vehicles 3.8 6.5 0.1 -- Smog Check Improvements (BAR) 3.3 2.9 0.05 -- Expanded Vehicle Retirement 0.5 0.7 0.01 -- Modifications to Reformulated Gasoline Program -- 2.9 -- --

Heavy-Duty Trucks 61.4 6.4 3.6 -- Cleaner In-Use Heavy-Duty Trucks 61.4 6.4 3.6 --

Goods Movement Sources 7.2 0.5 0.2 -- Ship Auxiliary Engine Cold Ironing & Clean Technology -- -- -- -- Cleaner Main Ship Engines and Fuel -- -- -- --

Port Truck Modernization -- -- -- --

Accelerated Introduction of Cleaner Line-Haul Locomotives 7.2 0.5 0.2 -- Clean Up Existing Harbor Craft -- NYQ -- -- Off-Road Equipment 3.7 0.9 0.8 -- Cleaner In-Use Off-Road Equipment (over 25hp) 3.7 0.9 0.8 -- Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ --

Other Off-Road Sources 0.1 3.5 -- --

New Emission Standards for Recreational Boats 0.1 1.3 -- -- Expanded Off-Road Rec. Vehicle Emission Standards -- 2.2 -- -- Additional Evaporative Emission Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 5.7 -- -- Consumer Products Program -- 3.2 -- -- Pesticides: DPR Regulation -- 2.5 -- --

Reductions from Proposed New State Measures 76 23 5 0

Reductions from Adopted State Measures 211 49 7 0

Total Emission Reductions from State Strategy 287 72 12 0

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation

Locomotives measure relie s on U.S. EPA’s rulemaking and indust ry agreement to accelerate fleet

turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed meas ure are shown for informational purposes only. Actual emission reductions from any particular me asure may be greater than or less than the amounts

shown.28 E. Reasonable Further Progress

The Act requires SIPs to provide for steady progress in reducing emissions during the years leading to the attainment date. This requirement provides a way to ensure continuous reductions prior to the attainment date. For PM2.5, U.S. EPA requires that the RFP plan show gener ally linear progress 7 for the precursor pollutants identified in the attainment demonstration, in this case , direct PM2.5, NOx, and SOx. Since the Valley will be in attainment in 2014, 2009 and 2012 are milestone years for RFP. Table 10 shows projected emission levels, showing continuous progress towards the

attainment levels.

Table 10. Projected Emissi on Levels in Milestone Years (in tpd)

Milestone

Year Direct PM2.5 NOx SOx

2005 86.0 575.4 26.4

2009 78.2 498.5 22.9

2012 70.3 415.8 22.9

2014 63.3 291.2 23.6

The SJV 2008 PM2.5 Plan meets RFP by achieving generally linear emission
reductions towards attainment in 2014 for direct PM2.5 and NOx from the 2005 baseline year through the milestone years 2009 and 2012. Percent year decreases in PM2.5 emissions range from 2 to 3 percent and in NOx emissions from 3 to 5 percent. SOx emissions in both milestone years ar e below the attainment level.

F. Contingency Measures

The Act requires attainment plans to provi de for contingency measures in the event the

nonattainment area fails to make RFP or fa ils to attain the PM2.5 standard by its

attainment date. These conti ngency measures are to take e ffect without further ARB or District action. U.S. EPA has interpreted this to mean that t he contingency measures must be from the pool of al ready adopted measures. The PM2.5 implementation rule language does not require any set percent of emission reductions for contingencies 8

.

ARB’s on-going mobile source program and the new measures in the State Strategy will

achieve the bulk of the emission reductions needed to attain the standards in the San Joaquin Valley. Historically, ARB’ s mobile source program has been very successful in reducing emissions in the Vall ey and throughout Californ ia. In addition,

ARB has a well established record of adopting and implementing mobile source regulations on time. The methods used in the SJV 2008 PM2.5 Plan to calculate

emission reductions needed to meet the RF P goals withheld reductions from the

7 72 FR 20633

8 72 FR 2066729 on-going mobile source control program as contingencies (SJV 2008 PM2.5 Plan, Chapter 8). For 2009 and 2012 RFP, 1 perc ent of PM2.5 and 3 percent of NOx baseline emissions are being reserved as cont ingencies, which result in reductions of about 1 tpd of PM2.5 and about 17 tpd of NOx. For attainment, the 2015 baseline emission reductions are relied upon to meet the contingency requirements. For NOx, baseline emission reductions provide for an additional 21 tpd in 2015. Between 2015 and 2017, an additional 60 tpd of additional NOx reductions will be achieved for contingency purposes.

The District supplements these contingency reductions with two additional contingency

measures. These measures re ly on fee- and incentive-base d funding that the District will spend to achieve emission reductions. Funding sources include the federallymandated 1-hour ozone nonattainm ent fee and incentive programs such as the Carl Moyer Program and Proposition 1B.

G. Reasonably Available Control Measure Analysis

Section 172 (c) of the Act r equires each nonattainment area to demonstrate that it has adopted all reasonably available control m easures (RACM), including reasonably available control technologies (RACT) for stat ionary sources, necessary to show that it will attain the federal standards as expedi tiously as practicable and to meet RFP requirements. RACM and RACT are those measures that are technologically and economically feasible within the nonattainment area. As part of the RACM/RACT demonstration, the District must show that there are no addi tional reasonable measures

available to the District t hat, when considered in aggr egate, would advance the attainment date by at least one year. In PM2.5 plans, the RACM/RACT analysis must

address direct PM2. 5, NOx and SOx.

1. District RACM

The SJV 2008 PM2.5 Plan includes the Distr ict’s RACM and RACT demonstration for direct PM2.5, NOx and SOx. The District followed U.S. EPA guidance for evaluating potential control measures as RACM. This RACM demonstr ation includes a comparison of stationary s ource measures the District has implemented or plans to implement with U.S. EPA’s li st of suggested PM2.5 cont rol measures. A detailed description of the District’s RACM analysis is found in Chapter 6 of the Plan. ARB staff has reviewed the analysis and concurs that the federal RACM/RACT requirement is

met.

2. Metropolitan Planning Organizations RACM

Following U.S. EPA guidance in their RACM analysis, the Valley’s Metropolitan Planning Organizations (MPO’s) conducted a review of Transportation Control Measures (TCMs) for possible consideration as local RACM . The analysis built on the MPO’s previous RACM analysis for the 2007 Ozone Plan and focused on NOx. The analysis found that the potential TCMs identif ied will not advance PM2.5 attainment by a30 full year, thus the SJV 2008 PM2.5 Plan doe s not include commitments to adopt any
TCM.

H. Transportation Conformity Budgets

Under section 176(c) of the Act, transportation activities t hat receive federal funding or approval must be fully consistent with the SI P. U.S. EPA’s transportation conformity

rule 9 details requirements for establishing mo tor vehicle emission budgets (budgets) in SIPs for the purpose of ensuring the confor mity of transportation plans and programs with the SIP. The budgets act as a “ceiling” fo r future on-road mobile source emissions. Exceedances of the budgets indicate an inconsistency with the SIP, and could jeopardize the flow of federal funds for transportation im provements in the region. Transportation agencies compare projected regional on-road mobile source emissions to these budgets during the periodic updates of regional transportation plans and

programs.

The SJV 2008 PM2.5 Plan establishes count y-level on-road motor vehicle emission budgets for each milestone year, as well as for the attainment year (Table 11). Emission budgets for direct PM 2.5 and the PM2.5 precursor NO x, were calculated using EMFAC2007 and reflect annual average emissions . Detailed calculations used to derive the transportation conformity budgets can be found in Chapter 7 and Appendix C
of the SJV 2008 PM2.5 Plan. The emission budgets est ablished in the SJV 2008 PM2.5 Plan fulfill the require ments of the Act and U.S. EPA regulations to ensure that transportation projects will not interfere with progress and attain ment of the annual

PM2.5 standard.

9 U.S. EPA maintains online inform ation on its transportation conformity program, including access to relevant rulemakings, policy guidance, and reports at: http://www.epa.gov/otaq/transp/traqconf.htm31 Table 11. Transportation Conformity Budgets (tons per annual average day)

2009 2012 2014 County PM2.5 (tpd) NOx (tpd) PM2.5 (tpd) NOx (tpd) PM2.5 (tpd) NOx (tpd)

Fresno 2.2 56.5 1.9 44.2 1.1 26.0

Kern (SJV) 3.4 87.7 3.0 74.2 1.4 41.6

Kings 0.7 17.9 0.6 14.6 0.3 8.1

Madera 0.6 14.1 0.5 11.4 0.3 6.7

Merced 1.5 33.6 1.2 26.7 0.6 14.8

San Joaquin 1.6 39.1 1.4 32.8 0.9 20.3

Stanislaus 1.0 25.8 0.9 20.8 0.5 12.4

Tulare 0.9 23.3 0.8 19.5 0.5 12.2

I. Environmental Impacts

The California Environmental Quality Act (CEQA) requires that State and local agency projects be assessed for potential signific ant environmental impacts. Air quality plans are “projects” that are potentia lly subject to CEQA requirement s. The District staff found that the Plan would not have a significant effect on the environment and prepared an Initial Study/Negative Declarat ion. The District Governing Board approved this Initial Study/Negative Declarat ion on April 30, 2008.

IV. STAFF RECOMMENDATION

We recommend that the Board take the following actions:

1. Adopt the SJV 2008 PM2.5 Plan, including the emission inventory, local control strategy, attainment demonstration, attainment deadline request, reasonable further progress plan, contingency m easures, RACT/RACM demonstration, transportation conformity emission budgets, and the commitment to conduct a mid-course review, as a revi sion to the California SIP

2. Direct the Executive Officer to submit the SJV 2008 PM2.5 Plan to U.S. EPA as a
revision to the California SIP.